Can a trust be regarded as a person for purposes of a double-taxation agreement to which South Africa is a party?

Authors :
Du Plessis, Izelle
Journal Title :
South African Law Journal
Citation :
2017 SALJ 907
Subject :
Trust - international double taxation
:
Trust may be regarded as a person for purposes of such a double-taxation agreement
:
Trustees exercise control over the trust assets, not for their own benefit, but for the benefit of the beneficiaries.

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